Neurology & Pain Management Coding Alert

Protect Your Consult Income By Following New CMS Rules

Check out Medicare's request regulations before you bill a consult

Neurology coders have known for years that consultations require a request from another clinician, but this year Medicare makes it clear that you must document that request in writing, finally ending speculation about whether you can report the consult codes based on verbal requests.
 
If you want to continue to collect for your neurologist's consultation services (99241-99255), make sure you follow CMS- new rules to the letter.

Get Request -- and Reason -- in Writing

On Dec. 20, 2005, CMS released Transmittal 788, which states, -A written request for a consultation from an appropriate source and the need for a consultation must be documented in the patient's medical record.-
 
The transmittal does give some slight wiggle room about when the written request can take place and states that the initial request may be a verbal interaction between the requesting physician and the consulting physician. However, both physicians should document the verbal conversation in the patient's medical record.

The Proof Is in Your Documentation Details

Even if both physicians document the request in writing, without a documented reason for the consultation you won't see any money for your neurologist's service. Make sure the requesting physician specifies in the original consultation request why the patient needs the service before you report a consultation code.
 
In the past, your physician may have simply written -neurology consult- at the top of his consult note when he performed a consultation at another physician's request. Instead, under the new guidelines, the doctor should write something like -neurology consult per internist's request- and include the reason for the internist's request.
  
The medical record should indicate if the physician requests a consult, CMS official Kit Scally said during the Jan. 20 physician Open-Door Forum. If an internist meets a neurologist in the hallway and verbally requests a consult, both physicians should document that fact. If one physician phones in the consult request to the other physician's staff, you should document that circumstance too, Scally said.

Capture All the Details With a Standard Form

CMS has also made it clear that your neurologist, as the consulting physician, must maintain a documented request in the patient's medical record, but the requesting physician now also has to include the request in the patient's medical record.
 
You can't simply make sure the requesting physician's file has the consulting physician's report after the fact. The request for the opinion must be in the requesting physician's chart before the consult happens, says Barbara Cobuzzi, MBA, CPC, CPC-H, CHBME, of CRN Healthcare Solutions in Tinton Falls, N.J.
 
Tip: You may consider using ordering slips when your physician requests a consult and asking for a written request when a physician sends a patient to you for consultation. If a colleague regularly sends patients to your office, you should give the requester ordering slips, similar to the ones radiologists and clinical labs use.
 
You can fax a form to the requesting physician's office, says Patricia Trites, MPA, CHBC, CPC, CHCC, CHCO, CEO of Healthcare Compliance Resources in Augusta, Mich.
 
The requesting physician can keep this form in the medical record, which solves your documentation problems and also helps you indicate the reason for the consultation request.
 
See the form -1 Simple Tool Can Make Your Consult Documentation Easy,- on page 52 for a sample fax request.

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